Hub and FCC QA Review Checklists

3. National Quality Review Structure

Introduction

This topic contains information on the national quality review structure, including

• hub and FCC QA review checklists
• general guidelines for quality reviews
• administrative comments
• determining whether a case is correct or in error
• deselections
• error citations when corrective action has already been taken
• reviewing all evidence
• clearly identifying and explaining errors
• appropriate citations
• cascade effect
• recording additional errors
• documentation of additional errors, and
• grace period for national quality errors.

Change Date

August 31, 2026

8.3.a. Hub and FCC QA Review Checklists

The QA process utilizes a series of checklists that outline potential errors. The available checklists used for fiduciary oversight are as follows:

• Accounting Quality Checklist
• Field Examination Quality Checklist
• FCC Quality Checklist, and
• Misuse Quality Checklist.

References: For more information on the

• Accounting Quality Checklist, see M21-4, 8, Appendix A.a
• Field Examination Quality Checklist, see M21-4, 8, Appendix B.a
• Misuse Quality Checklist, see M21-4, 8, Appendix C.a, and
• FCC Quality Checklist, see M21-4, 8, Appendix D.a.

8.3.b. General Guidelines for Quality Reviews

P&F Service QA review process records errors when actions are taken that violate current regulations or other directives. Errors cited must affect or potentially affect outcome.

Substantive (or critical) errors (SEs) are errors that impact national quality. SEs must affect or potentially affect outcome, and directly impact the beneficiary.

To be considered an SE, the citation must fall within the following categories:

• prevention of Department of Veterans Affairs (VA) negligence
• protection of beneficiaries, or
• correct payment.

Errors cited under the entitlement issues and beneficiary sections on the QA Review Checklist that do not fall into the categories above are considered non-substantive (or non-critical) and do not affect national quality, however, may require correction.

Note: The SE accuracy rate is the official measure of Fiduciary Program quality accuracy and is used for performance measurement purposes.

Reference: For more information on completing corrections, see M21-4, 8.5.b.

8.3.c. Administrative Comments

Administrative comments do not rise to the level of substantive errors. These deficiencies are usually recorded as

• decision documentation
• notification
• administrative (internal controls), or
• an error identified with an issue not related to the work item or call recording under review.

8.3.d. Determining Whether a Case is Correct or in Error

For each case or call recording reviewed, the case or call recording is considered either correct or in error (i.e., it is either entirely correct or it is wrong).

Important: An answer of No to any of the questions on the checklist relating to the processing of the work item or call recording under review will result in the case or call recording being classified as in error.

Note: The last section of the QA review checklist contains an area for administrative comments. An answer of No for one of these questions will not indicate an error in the case but may require corrective action.

8.3.e. Deselection

Deselect the case or call recording if any of the following conditions are met:

P&F Service conducts QA reviews on selected cases to ensure a statistically valid sample. In rare instances, when a review may not be appropriate, P&F Service will deselect the case or call recording if there is no other alternative. To maintain a statistically valid sample size, P&F Service will assign replacements for deselected cases and call recordings during the same or next monthly sample selection.

• There is no basis for the established EP. Example: No documentation to support the existence of the EP.
• The hub credited for the completion of an EP did not complete the EP.
• The employee that conducted the EP under review did not belong to the hub credited for the EP when it was completed.
• The call recording has no sound.

Do not deselect the case or call recording if any of the following conditions are met:

• The competency determination is not decided prior to fiduciary actions. Example: Prior to final competency determination the initial fiduciary field exam has been conducted.
• The EP under review is wrong or was prematurely cleared but decided. Example: In this instance, the fiduciary analyst updates the system to reflect the discrepancy as a comment when reviewing the EP.
• The beneficiary is deceased. Example: Beneficiary passes away prior to VA notification and hub actions are needed/completed.
• There is a pending appeal or an Office of Inspector General (OIG) investigation. Example: There is evidence of record of a pending appeal or OIG investigation.
• The call recording is documented in the Veterans Benefits Management System (VBMS) but is determined to not be a fiduciary issue.
• The call recording unexpectedly drops.

8.3.f. Error Citations When Corrective Action Has Already Been Taken

QA will not cite errors on EPs selected for Systematic Technical Accuracy Review (STAR) assessment where hubs discovered the error(s), made proper correction(s), and cleared the correcting EP before the case was selected for STAR assessment, regardless of whether the claimant received incorrect notification.

However, if a correcting EP is established and still pending, or if the correcting EP was previously established and cleared with final corrective action on or after the Quality Management System (QMS) run date, QA will cite the error(s) made on the EP under STAR assessment. Actions taken on the correcting EP are also subject to STAR assessment.

Note: The QMS run date is the date PA&I pulls the case for national quality review and the date the review record is created.

Example: A claim with a transaction date of January 15, 2024, is selected for STAR assessment. The run date shown in QMS is February 1, 2024. On February 8, 2024, the hub identified an error on the claim prior to QA finalizing the STAR assessment. QA will cite any error(s) on the EP because the run date is earlier than the date the hub identified the error.

If the hub had identified the error(s) and completed corrective action on or before January 31, 2024, no error would be cited on the hub.

8.3.g. Reviewing All Evidence

QA staff must thoroughly review each facet of an EP and call recording. It is not sufficient to simply review a decision, the letter of notification, and/or call recording documentation. QA staff must review all the evidence associated with an EP or call recording and ensure the hub or FCC properly addressed all issues.

8.3.h. Clearly Identifying and Explaining Errors

P&F Service will provide sufficient narratives to clearly identify and explain the error cited. Clear explanations for error(s) cited allow a reader to understand the problem area(s) without reviewing the electronic claims folder (eFolder) or listening to the call recording. If the corrective action required is not the obvious corrective action, then a statement indicating what corrective action is required will be provided.

8.3.i. Appropriate Citations

Provide appropriate citations supporting error calls. The reference must cite the appropriate statute or regulation, such as:

• FPM or FCC procedures
• supporting statutes and regulations
• Court of Appeals for Veterans Claims (CAVC) opinions
• General Counsel opinions
• General Counsel precedent decisions, or
• policy letters.

8.3.j. Cascade Effect

Based on the logical progression of the quality review checklist, when an error is identified, generally subsequent processing related to that issue will also be in error. This pattern of derived error is referred to as a cascade effect.

Example: If funds under management (FUM) are not properly verified during a field examination, an error exists in this regard. As a result, additional errors such as failing to request the appropriate protection may exist. P&F Service will cite the error responsible for the cascading errors and document any corrective actions.

8.3.k. Recording Additional Errors

Recording additional errors inherent in the initial deficiency would distort identification of the basic or critical errors of the case, while adding little or no insight into root causes or the error itself.

QA reviews are outcome-oriented and not process-oriented. Once an error concerning a specific issue associated with a claim (e.g., a No answer for one of the checklist questions) is detected and recorded, do not record additional errors related to that issue. Continue to review the case or call recording for any other issues subject to review and record the first error found in processing each additional issue contained within the EP or call recording.

8.3.l. Documentation of Additional Errors

Once the QA staff identifies one substantive error, the entire case or call recording is considered to be in error. Any additional errors found and documented will not change the outcome for a particular case or call recording, since any one critical error (a No answer) makes the entire action incorrect.

Documentation of additional critical errors, however, will provide valuable information about the nature of primary errors and a better definition of the extent of accuracy concerns for the hub, FCC, RO Director, or district office review (i.e., of the cases in error, how many total critical errors were identified and in what categories).

8.3.m. Grace Period for National Quality Errors

P&F Service will provide a 30-calendar day grace period on any new manual changes or substantive changes to existing procedures before officially citing a national quality error. For hubs and the FCC, the 30-calendar day grace period is counted as 30 calendar days after the relevant information is published.

Example: The FPM Key Changes document shows new manual guidance is published on January 20, 2020, so the grace period includes the next 30 calendar days. Errors based on the new guidance would be cited with EPs completed on and after February 19, 2020.

Notes:

• This grace period does not apply to clarifications of existing guidance.
• P&F Service may choose to apply a different grace period in select circumstances and will notify the hubs in writing of any deviation to the 30-day grace period standard.